In re Shriram Paper Industries (GST AAR Haryana)
The Haryana Authority for Advance Ruling considered the application of M/s Shriram Paper Industries concerning classification and GST rate of boards manufactured entirely from agricultural crop residues such as bagasse, paddy straw, wheat straw and mustard straw. The applicant stated that no wood, resin, synthetic adhesive or chemical binder is used. The manufacturing process involves cleaning, cooking or steaming, mechanical refining into fibres, sheet formation, drying, calendaring, cutting and hot pressing, with bonding through the natural properties of the fibres. The finished products are marketed as “Straw Board”, “Agro Board” or “Eco. Board” and supplied for bookbinding, file boards, stationery, packaging support layers and furniture backing applications. The application was found maintainable under Section 97(2) of the CGST/HGST Acts, as the questions concerned classification of goods under Section 97(2)(a) and applicability of a notification under Section 97(2)(b). The applicant had also declared that the issue was neither pending nor decided in its own case, and the application was admitted on merits.
The Authority identified the principal issues as whether the goods constitute particle board or fibre board, their appropriate classification under the Customs Tariff Act, 1975, applicability of Entry No. 292(h) of Notification No. 9/2025-Integrated Tax (Rate) dated 17 September 2025, interpretation of the expression “HSN 44 or any chapter”, and the persuasive value of earlier rulings concerning similar products. Heading 4411 covers “Fibre board of wood or other ligneous materials, whether or not bonded with resins or other organic substances.” The Authority considered the relevant HSN Explanatory Notes, which state that fibreboard may be manufactured from wood chips or other defibred ligneo-cellulosic material, including bagasse, and that fibres may be bonded through their natural felting properties or with additives. The Authority therefore noted that resin is not an essential ingredient for fibreboard.
